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Privacy Policy

RIVERWIND BANK PRIVACY POLICY

The following is the RiverWind Bank’s policy as regards the privacy of customer information:

We do not disclose nonpublic personal information about our customers to anyone, except as permitted by law. This includes providing customer information obtained from other sources (information not based upon our customers’ history or transactions with our bank) to our own affiliates.

The law allows the following exemptions for processing and servicing transactions, as follows:

Servicing or processing a financial product or service that a consumer requests or authorizes.

Maintaining or servicing the consumer’s account as part of a private label credit card program or other extension of credit on behalf of such entity.

Proposed or actual securitization, secondary market sale (including sale of servicing rights), or similar transaction related to a transaction of the consumer.

RiverWind Bank can also disclose customer information:

With the consent or at the direction of the consumer,

To protect the confidentiality or security of a RiverWind Bank’s records pertaining to the consumer, service, product or transaction,

To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability,

For required institutional risk control or for resolving consumer disputes or inquiries,

To persons holding legal or beneficial interest related to the consumer,

To persons acting in a fiduciary or representative capacity on behalf of the consumer,

To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating a RiverWind Bank, persons that are assessing the RiverWind Bank’s compliance with industry standards, and the RiverWind Bank’s attorneys, accountants and auditors,

To law enforcement agencies and regulators to the extent permitted or required by law,

To a consumer reporting agency in accordance with Fair Credit Reporting Act,

In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of a business or operating unit,

To comply with Federal, State or local laws, rules and other applicable legal requirements,

To comply with a properly authorized civil, criminal or regulatory investigation or subpoena or summons, or

To respond to judicial process or government regulatory authorities having jurisdiction.

RiverWind Bank’s Privacy Notice will be provided to all existing customers (as defined by regulation) as of July 1, 2001 to comply with the requirements of Regulation P. All new customers will receive the Privacy Notice at the time their account relationship is opened. An annual Privacy Notice will be distributed to all existing active customers at a set time each year.

RiverWind Bank will not disclose account numbers, or a similar form of access number or access code, for a consumer’s credit card account, deposit account, or transaction account to any nonaffiliated third party for marketing purposes, except as allowed for the RiverWind Bank’s own marketing efforts.

Contracts with service providers will be modified to include requirements that the third-part maintain the confidentiality of customer information.

RiverWind Bank's policy is to assure that customer information is accurate. RiverWind Bank restricts access to customer information to those employees who need to know that information to provide products and services. RiverWind Bank maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.